Jay M. Anderson and Helen B. Anderson - Page 12

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            Petitioner's J Car Activity                                                                 
                  If an activity is one "not engaged in for profit", section                            
            183 limits the deductions allowed with respect to that activity.                            
            First, section 183(b)(1) allows the full amount of those                                    
            deductions available without regard to the profit objective of                              
            the activity.  Then, section 183(b)(2) allows those deductions                              
            normally permitted only if such activity were engaged in for                                
            profit, but limits them to the amount by which the gross income                             
            from that activity exceeds any deductions taken under section                               
            183(b)(1).  Section 183(c) defines an activity not engaged in for                           
            profit as any activity other than one with respect to which                                 
            deductions are allowable under section 162 or section 212.                                  
                  Whether deductions are allowable under section 162 or                                 
            section 212 depends upon whether the taxpayer engaged in that                               
            activity with the "actual and honest objective of making a                                  
            profit."  Ronnen v. Commissioner, 90 T.C. 74, 91 (1988); Dreicer                            
            v. Commissioner, 78 T.C. 642, 645 (1982), affd. without opinion                             
            702 F.2d 1205 (D.C. Cir. 1983).  The taxpayer's expectation of                              
            profit need not be a reasonable one; however, the taxpayer must                             
            have a bona fide objective to make a profit.  Hulter v.                                     
            Commissioner, 91 T.C. 371, 393 (1988); Allen v. Commissioner, 72                            
            T.C. 28, 33 (1979); Dunn v. Commissioner, 70 T.C. 715, 720                                  
            (1978), affd. without published opinion 607 F.2d 995 (2d Cir.                               
            1979), affd. on another issue 615 F.2d 578 (2d Cir. 1980).                                  






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